PROGRAM ABUSE PREVENTION PLAN - ProAct, Inc.€¦ · Revised 03/06/2012 Maltreatment of...

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Page 1 of 24 Page 1 of 24 H:\245D Forms PDFs\policy-i-78-f_rw_program_abuse_prevenplan.doc Program Abuse Prevention Plan Program: ProAct Red Wing Address: 204 Mississippi Ave Red Wing, MN 55066 Date plan developed: 1/13/2014 This document is a description of the Program Abuse Prevention Plan for the Red Wing Site, including the Satellite Site, effective January 1, 2014 Maltreatment of Minors/Vulnerable Adult Maltreatment Policy/Procedure For reporting incidents of Vulnerable Minor or Adult Maltreatment can be found in the I-78PP Policy and Procedures Manual (Eagan/Red Wing/Zumbrota/Hudson) 3195 Neil Armstrong Blvd Eagan, MN 55121 651-686-0405 204 Mississippi Avenue Red Wing, MN 55066 651-388-7108 224 Main Street Zumbrota, MN 55992 507-732-7888 1202 Beaudry Blvd Hudson, WI 54016 715-410-4216 Revised 01/27/2014 Revised 03/06/2012 Revised 01/25/2012 PROGRAM ABUSE PREVENTION PLAN I-78-F

Transcript of PROGRAM ABUSE PREVENTION PLAN - ProAct, Inc.€¦ · Revised 03/06/2012 Maltreatment of...

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Program Abuse Prevention Plan

Program: ProAct Red Wing

Address: 204 Mississippi Ave Red Wing, MN 55066

Date plan developed:

1/13/2014

This document is a description of the Program Abuse Prevention Plan for the Red Wing Site, including the Satellite Site, effective January 1, 2014

Maltreatment of Minors/Vulnerable Adult Maltreatment

Policy/Procedure For reporting incidents of Vulnerable Minor or Adult Maltreatment can

be found in the I-78PP Policy and Procedures Manual (Eagan/Red

Wing/Zumbrota/Hudson)

3195 Neil Armstrong Blvd Eagan, MN 55121 651-686-0405

204 Mississippi Avenue Red Wing, MN 55066 651-388-7108

224 Main Street Zumbrota, MN 55992 507-732-7888

1202 Beaudry Blvd Hudson, WI 54016 715-410-4216

Revised 01/27/2014 Revised 03/06/2012 Revised 01/25/2012

PROGRAM ABUSE PREVENTION PLAN

I-78-F

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PROGRAM ABUSE PREVENTION PLAN TABLE OF CONTENTS

245D PROGRAM ABUSE PREVENTION PLAN Pages 3-6 ASSESSMENT OF THE POPULATION Red Wing Satellite Site Pages 5-6 Summary Page 6 Alternate Sites Page 6 STAFF SUPERVISION/RATIO REQUIREMENTS Pages 6-7 PLAN REVIEW Page 7 PLAN ORIENTATION FOR PERSONS SERVED Page 7 PLAN DISTRIBUTION Page 7 RED WING EXTENDED EMPLOYMENT PROGRAM Pages 7-11 EMPLOYMENT TRAINING SERVICES Pages 7-11 ANNUAL INCIDENT REVIEW AND REPORT Pages 11-14 MANDATED REPORTERS Page 15 Attachments: Confidential Reporting Form Sample Page 16 POPULATION ASSESSMENT Pages 17-20 PHYSICAL PLANT ASSESSMENT Pages 20-21 ENVIRONMENTAL ASSESSMENT Pages 21-24

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Day Training and Habilitation – Program Abuse Prevention Plan The persons served by the DTH are considered to be Vulnerable Minors and Adults as defined by the consolidated standards - Minnesota Rules, under section 626.556 (maltreatment of minors) and 626.557 (vulnerable adults) and are susceptible to maltreatment. It is ProAct policy to: A. Report maltreatment of minors or vulnerable adults B. Provide a Program Abuse Prevention Plan C. Provide an Individual Abuse Prevention Plan for each person served. D. Provide training and information about the Maltreatment of Minors/Vulnerable Adult ct to each person served or to their legal representatives. ProAct, Inc. staff members continue to use checklists in all building areas and for all participants at transport times. During this period the directors, programs & services and appropriate staff members completed periodic reviews of all incident reports at the Red Wing site. Annually, those incident reports are analyzed for trends, actions needed and/or staff training needed. The satellite of the Red Wing DT&H at Zumbrota serves up to 12 individuals. The existing building housing the Zumbrota DT&H is adequately sized to accommodate both programs. At the Red Wing Site: there were multiple uses of emergency controlled procedures; refer to monthly listing and annual incident review of this document. Appropriate reports were provided/meetings held as per procedure. Safety procedures continue to be reviewed at time of hire and annually thereafter with staff members. The Internal Review was completed re: the use of those actions/programs with no modifications needed.

Red Wing Satellite Site: At the Red Wing Satellite site, there are up to 12 individuals served daily. These are individuals who may reside in the local area of Zumbrota, Wanamingo & surrounding rural areas, and who currently are served at the Red Wing DT&H location. Frequent outings, classes and enrichment activities incorporate preferred options for all individuals. There are primary service spaces for the satellite group. The kitchen, bathrooms, and sunroom will be shared spaces accessible to both groups, frequently at different times of day, or as needed. Within the satellite group, individuals who are at risk for becoming upset by activity, change or noise, or who are having difficult periods, may be moved to a quiet area to listen to music or to use other methods to relax depending on individual program plans. Safety procedures continue to be reviewed at time of hire and annually thereafter with staff members. Cases of repeated incidents involving the same individual(s) are referred to the appropriate case manager for further analysis and discussion with the individual teams. A report of suspected maltreatment shall be reported and investigated. The reporter shall follow the procedure outlined, in policy and procedures Manual (I-78PP). This report is then dealt with as per the Maltreatment of Minors/Vulnerable Adults Act procedures (When appropriate, verbal report to the Common Entry Point with documentation in ProAct, Inc. records using the R-107). The program maltreatment prevention plan, and the individual abuse prevention plans, are developed to protect persons served, train staff members, and orient team members to the prevention of self abuse, financial exploitation, physical abuse, neglect, serious illness/injury, fires, elopement, suicide attempts, humiliation, retaliation and persistent emotional or psychological abuse of persons served, as

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well as to train all persons on the rights and responsibilities of persons served and mandated reporters as they pertain to the common entry point reporting system. Annually, there is a review of incidents, accidents, and medication errors. In 2013, there were two reports to the common entry point of individuals transported home and left there without staff members present. An investigation followed both incidents. The bus drivers involved were retrained and directed to closely monitor the time they left ProAct. Other drivers were also retrained. The program maltreatment prevention plan, and the individual abuse prevention plans, are developed to protect persons served, train staff members, and orient team members to the prevention of self abuse, financial exploitation, physical abuse, neglect, serious illness/injury, fires, elopement, suicide attempts, humiliation, retaliation and persistent emotional or psychological abuse of persons served, as well as to train all persons on the rights and responsibilities of persons served and mandated reporters as they pertain to the common entry point reporting system. A DTH Assessment/Abuse Prevention Plan is written for each person. This plan is based on an assessment of vulnerability and combined with the facility plan. The assessment will include information regarding any history of previous abuse by/to the person. The Individual Plan is reviewed quarterly along with any incident reports which have been filed or any changes which have occurred in the person's life which would indicate a change in the plan is needed. Each new person is assessed as to his/her vulnerability and an Individual Plan is written. Thereafter, an assessment of vulnerability and new plan are done at the time of the Annual Review for the person. Program staff participates in training for dealing with difficult behaviors and medical emergencies, with individual plans, and to learn positive reinforcement techniques. ProAct, Inc., as individual needs arise, will use consultants. Assessment documents are used to assist staff in understanding a variety of behaviors presented by persons served. New staff members are oriented to the revised Maltreatment of Minors/Vulnerable Adults Act, to reporting procedures and to the ProAct, Inc. Vulnerable Minors and Adults/Maltreatment Prevention Policy and Procedures Manual (I-78PP) or the General Policy & Procedure Manual. Program Specialists/Case Managers along with the IDT, develop the Individual Abuse prevention Plans and train other staff working with persons served. Specialized training/staff assistance is provided to persons served in the areas of communication, visual skills, behavior management, activities of daily living, safety, motor development, social skills, and transportation. This list is not totally inclusive, since training/staff assistance is provided to any person on an individual basis or in small groups, as areas of vulnerability arise or when it appears that specialized instruction is indicated. The manner in which instruction is provided depends on the person's best mode of learning; training is provided individually and in small groups on procedures to follow, reporting, and appropriate methods of self-protection, when the person is able to benefit from such instruction. Otherwise, staff will be trained to be sensitive to, and aware of individual needs. The consulting Goodhue County Public Health Nurse, Lily Eustis, provides supervision of staff at both sites. The personal physician for each consumer is consulted as needed either by the PHN or a ProAct staff member. Some of the persons served at both locations have needs for speech, music and/or occupational or physical therapy. All three therapies are either provided on-site or arranged for at both locations to approved persons when prescribed by a physician. Otherwise, activities arranged by ProAct, Inc.'s human service technicians or other staff is available as desired by IDT request. Sensory integration or

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therapy follow-through techniques are implemented with individuals who appear to benefit from such techniques or when prescribed by a health professional. ASSESSMENT OF THE POPULATION RED WING SITE The ProAct, Inc.-245D program serves men and women who are Minnesota or Wisconsin residents aged 18 and older. Intellectual capacities range from mildly to profoundly developmentally disabled. Physical functioning and abilities range from normal physical condition to significant dependence on others for activities of daily living. Disabilities of persons served may range from visual impairments, hearing deficits, epilepsy, non-ambulation, and sensory/motor problems which affect coordination, movement, communications, and ability to understand one's surroundings. Behaviors observed may include aggression, wandering/running away, and self abuse, many kinds of attention getting and disruptive behaviors, and non-compliance with program activities. This group includes persons with cognitive impairments and several persons who need programming at a 1:1 staffing level for portions of each day. During the period of January 1, 2013 to December 31, 2013, there were 148 total persons who received services under the DTH license. There were 9 new admissions and 10 discharges. RED WING SATELLITE SITE The Red Wing Satellite DT&H has a license capacity of 12 persons. This group consists of participating consumers from the Red Wing DT&H site who may reside in the Zumbrota & Wanamingo areas, or may reside in other locations, including Wisconsin. This will be a mixed group of full-time and part-time consumers including men and women of ages ranging from transition students to retirement age. Outings, center-based work training, classes, and activities of interest are offered. Mental capabilities range from mildly to significantly impaired. Physical functioning and abilities range from full physical ability to dependence upon others for activities of daily living (transferring and hand-over-hand instruction). Consumer behavior programs include assistance with managing a variety of issues such as aggression (verbal/physical), property destruction, and elopement, various attention getting and disruptive behaviors and noncompliance with program activities. There are consumers who utilize wheelchairs, walkers and canes. Program staff participate in a minimum of 40 hours of extensive orientation & training upon hire as well as annual retraining of 20 hours. In addition, there are ongoing sessions for dealing with problem behaviors, as well as appropriate and effective reinforcement techniques. The program has access to a consulting psychologist, nurse consultant and behavior training expertise as well as staff to assist with personal care. Identified program consumers’ needs are addressed in their individual program plans as well as in their abuse prevention plans.

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IN SUMMARY Red Wing has 33 persons in wheelchairs or with disabilities that limit their ability to move away from an aggressor and who must be assisted by staff. Their individual plans address specific ways to protect each one from harm or injury. Red Wing has 28 persons who have been aggressive to others in the past. Ten in Red Wing have inflicted injury to others. Many persons in Red Wing may at times become aggressive to others and are vulnerable to abuse from others. Both the program abuse prevention plan and the individual abuse prevention plans detail methods for preventing and/or coping with such behaviors at all sites. Staff members are trained to use intervention strategies for behavior management as needed, according to individual plans, before they begin to work with persons served, annually, and as needed. ProAct, Inc. offers Crisis Prevention Institute (CPI) training to staff members. Staffing is provided according to the needs addressed in the Individual Plan for each participant. Individuals receiving services in the satellite setting receive services according to their individual ratios, generally 1:4 or 1:6. The Zumbrota Clinic is only a few minutes away for medical emergencies. The Goodhue County Public Health Nurse consultant visits as arranged, is on-call, provides overall supervision, assists with problem-solving, and reviews policies. The President and Director, Programs & Services visit as needed to deal with staff, services, and training issues. The Site Manager and/or other Zumbrota staff attend trainings, meetings and participate in other functions at ProAct-Red Wing. ALTERNATE SITES Persons are served in Red Wing and the Zumbrota site on a regular basis for classes, a base for community integration activities, and work training. Weather, health problems or other individual needs may mean that an alternate site will be used. Each person served chooses a combination of activities for this day. Staff Supervision/Ratio Requirements Services are staffed to allow for adequate supervision of all involved program consumers and to meet the individual's staff ratio as determined by the following criteria: ONE TO FOUR RATIO (1:4): Requirements are that a person must have one or more of the characteristics described in the following two items (there are 28 individuals within this ratio).

A. On a daily basis the person requires total care and monitoring or constant hand-over-hand physical guidance to successfully complete at least three of the following activities: toileting, communicating basic needs, eating or ambulating.

B. The person assaults others, is self-injurious, or manifests severe dysfunctional behaviors at a documented level or frequency, intensity, or duration requiring frequent daily on-going intervention and monitoring as established in an approved behavior management program.

ONE TO SIX RATIO (1:6): Requirement is that a person who does not have the characteristics described for ratios of 1:4 or 1:8 must be assigned a staff ratio of 1:6. There are 47 individuals within this ratio.

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ONE TO EIGHT RATIO (1:8): Requirements are that a person must have all of the characteristics described in the following two items: (there are 46 individuals within this ratio) A. The person does not meet the requirements for a one- to-four ratio. B. On a daily basis the person requires verbal prompts or spot checks and minimal or no physical assistance to successfully complete at least three of the following activities: toileting, communicating basic needs, eating or ambulating. ONE TO ONE RATIO Long Term DT&H Program services offered consist of the following:

Vocational services - facility and community based

Community integration/independent living skills

Self-care training

Community orientation training

Mobility training

Social and communication skills training

Safety practices training

Vocational skills training

Specialized therapies/consultation PLAN REVIEW The DT&H Vulnerable Minor and Adult/Maltreatment Prevention Plan is reviewed annually by the Director, Programs & Services and the Board of Directors. Reports of abuse, neglect, exploitation or changes in the population, physical plant, or environment or trends gleaned from incident reports will be used to make any revisions to the plan. PLAN ORIENTATION FOR PERSONS SERVED Each person served or his/her representative will be oriented to the 245D Vulnerable Minor or Adult/Maltreatment Prevention Plan within 24 hours of admission to the program or within 72 hours if that delay would benefit the person served, and will also be reviewed annually. PLAN DISTRIBUTION A copy of the plan will be posted in the 245D service areas and a copy will be available to the applicant or representative at the time of admission, annual review, and upon request at anytime. The date of last review will be indicated on the plan. RED WING EXTENDED EMPLOYMENT PROGRAM/EMPLOYMENT TRAINING SERVICES Persons served by extended employment services or employment training services, prevocational type, are considered to be Vulnerable Adults. It is the policy of ProAct, Inc. to: Report maltreatment of vulnerable adults Provide an extended employment program/Program Abuse Prevention Plan

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Provide, as needed and where appropriate, assistance in developing a plan of support to deal with identified vulnerabilities. Provide training and information about abuse/protection to each person served or to their legal representatives. A report of suspected maltreatment shall be reported and investigated. The reporter shall follow the procedure outlined in Policy and Procedures Manual (I-78PP). This report is then dealt with as per the Vulnerable Adults Act procedures (When appropriate, verbal report to the Common Entry Point). The facility vulnerable adult maltreatment prevention plan is reviewed and revised as needed by program staff. Incident reports will be summarized annually by the director, programs & services, and the results analyzed by the safety committee. Each person served will be advised on admission, of ProAct, Inc.'s vulnerable adult maltreatment prevention plan, and instructed to report any maltreatment. Annual training will be offered that pertains to personal safety, reporting of maltreatment, maltreatment of minors and vulnerable adult law, and/or suggestions for dealing with difficult persons. This information will be posted on the break room bulletin board, and a copy will be available to the applicant at the time of admission, annual review, and upon request at any time. The date of last review will be indicated on the plan.

For the period January 1, 2013 to December 31, 2013, there were no reports of possible maltreatment of a vulnerable adult served in EE/Employment Training Services at ProAct – Red Wing. There were 156 individuals served in these two programs. ProAct, Inc. staff members continue to use checklists in all building areas and for all participants at transport times. During this period the director, programs & services and appropriate staff members completed an annual review of all incident reports. Safety procedures continue to be reviewed at time of hire and annually thereafter with staff members. Cases of repeated incidents involving the same individual(s) are referred to the appropriate case manager for further analysis and discussion with the individual teams. A report of suspected maltreatment shall be reported and investigated. The reporter shall follow the procedure outlined, in policy and procedures Manual (I-78PP). This report is then dealt with as per the Vulnerable Adults Act procedures (When appropriate, verbal report to the Common Entry Point with documentation in ProAct, Inc. records using the R-107). The program abuse prevention plan, and as needed, the individual abuse prevention plans, are developed to protect persons served, train staff members, and orient team members to the prevention of self abuse, financial exploitation, physical abuse, neglect, fires, serious injury/illness, suicide attempts, humiliation, retaliation and persistent emotional or psychological abuse of persons served, as well as to train all persons on the rights and responsibilities of persons served and mandated reporters as they pertain to the common entry point reporting system. An Assessment/Abuse Prevention Plan is written for each person. This plan is based on an assessment of vulnerability and combined with the facility plan. The assessment will include information regarding any history of previous abuse by/to the person. The Individual Plan is reviewed semi-annually along with any incident reports which have been filed or any changes which have occurred in the person's life which would indicate a change in the plan is needed. Each new person is assessed as to his/her vulnerability and an Individual Plan may be written. Thereafter, an assessment of vulnerability and new plan are done at the time of the Annual Review for the person. (R-118)

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Program staff participate in initial/ongoing training for dealing with difficult behaviors, medical emergencies, individual plans, & appropriate positive reinforcement techniques. New staff members are oriented to the revised Vulnerable Adults Act, to reporting procedures and to the ProAct, Inc. Program Abuse Prevention Policy and Procedures Manual (I-78PP). ProAct Case Managers team with the IDT, develop the Individual Abuse Prevention Plans and train other staff working with persons served. Specialized training/staff assistance is provided to persons served in the areas of communication, visual skills, behavior management, activities of daily living, safety, motor development, social skills, and transportation. This list is not totally inclusive, since training/staff assistance is provided to any individual or in small groups, as areas of vulnerability arise. Instruction is provided depending on the person's best mode of learning; training is provided individually/in small groups on procedures to follow, reporting, and self-protection, as appropriate. Staff are trained to be sensitive to, and aware of individual needs. The consulting Goodhue County Public Health nurse provides supervision of staff. The personal physician for each consumer is consulted as needed by the PHN or a ProAct staff member. Persons served may have needs for speech or other therapy. All therapies are provided on site or arranged for when prescribed by a physician. Otherwise, activities arranged by ProAct, Inc.’s rehabilitation assistant or other staff are available as desired by IDT request. Sensory integration or therapy follow-through techniques are implemented with individuals who appear to benefit from such techniques. ASSESSMENT OF THE POPULATION ProAct, Inc. serves men and women who are Minnesota or Wisconsin residents aged 18 and older. Intellectual capacities range from profoundly developmentally disabled to well above average. Physical functioning and abilities range from normal physical condition to some dependence on others for activities of daily living. Disabilities of persons served may range from visual impairments, mental illness, hearing deficits, epilepsy, non-ambulation, and sensory/motor problems which affect coordination, movement, communications, and ability to understand one's surroundings, and other conditions. Behaviors observed may include wandering/running away, self abuse, attention getting and occasional non-compliance with program activities. Staff members are trained to use intervention strategies for behavior management as needed, according to individual plans, before they begin to work with persons served, annually, and as needed. ProAct–Red Wing offers Crisis Prevention Institute (CPI) training to staff members. Through contracted services, assessments followed by speech therapy services are provided when ordered by a physician. ASSESSMENT OF THE PHYSICAL PLANT The ProAct-Red Wing plant is located in the Industrial Park, approximately five miles north of Red Wing. The building meets all fire and safety requirements. It is an integrated plant, employing production workers as well as adults with disabilities. Restrooms are fully accessible. All persons are oriented to moving to areas of safety or exit in case of emergency or fire. There are three electric doors providing egress from the break room that allow independence for those with ambulatory problems and two more (DTH workroom #1 bathroom) and (DTH lunchroom to conference room) for other needs. Any person subject to wandering remains under staff supervision throughout the entire day. Persons are supervised as needed when in areas of the building that are shared with participants and staff of other programs, production workers, and visitors.

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The fire door between the old & new sections of the building has an electric door opener. The fire bell warning system includes red flashing lights for hard of hearing/deaf persons. There is an automatic pushbutton-operated door on the main entrance to the building, a lowered front counter in the reception area and a flashing red light warning system in the front office. The production floor includes a large classroom and small meeting room for EE/ETS use, with enhanced heating and air conditioning. Off the consumer break room, there is a remodeled kitchen area where cooking/food classes are held. ProAct-Red Wing has access to community work sites to provide both work services and community orientation services. Each work site is assessed by ProAct, Inc. staff members prior to beginning the job. Each person is then oriented to the work site and supervision is provided accordingly. Work sites and assignments are subject to change based on individual needs and responses to that environment. ASSESSMENT OF THE ENVIRONMENT The Work Services Center is located in an industrial setting. Truck traffic is routed to the back of the building. Adjacent companies are generally acquainted with ProAct-Red Wing clientele. ProAct-Red Wing has a covered shelter, picnic tables and an outdoor lawn area for breaks and lunch as desired. Persons receiving services who are inclined to wander off grounds are carefully monitored by staff, and appropriate action is taken to insure their safety. ProAct-Red Wing has an elopement policy which is implemented as needed. Staff members supervise all breaks and pre-work time. Surrounding businesses typically will call ProAct-Red Wing if they notice a vulnerable adult going up the street. Whenever areas of potential hazard to persons served or staff are reported, appropriate action will be taken within 24 hours to correct the problem. If more time is required, the hazard will be secured to prevent access by a vulnerable adult. All areas that are potentially hazardous to persons served have been secured in such a fashion as to remove the hazard. The appropriate doors are kept locked at all times and are posted with an “authorized personnel only” sign. All areas difficult to supervise are “off limits” to persons served. PLAN REVIEW The Vulnerable Adult/Minor Program Abuse Prevention Plan is reviewed annually by the Director, Programs & Services. Reports of abuse, neglect, financial or other exploitation, retaliation, humiliation, or changes in the population, physical plant, or environment or trends gleaned from incident/complaint reports will be used to make any revisions to the plan. ProAct implements policies that promote confidentiality of information, privacy, informed consent/refusal as appropriate, access to advocacy services, investigation of alleged infringement of rights, and adherence to standards of ethics where persons served are involved. PLAN ORIENTATION FOR PERSONS SERVED Each person served or his/her representative will be oriented to the Vulnerable Adult/Minor Maltreatment Prevention Plan at the time of admission to the program and will be reviewed annually.

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PLAN DISTRIBUTING A copy of the plan will be posted in the work service areas and a copy will be available to the applicant or representative at the time of admission, annual review, and upon request at anytime. The date of last review will be indicated on the plan.

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MEMO

To: Steve Ditschler, President/CEO; Dave Cavalier, Production Director, DTH, EE & Adult Day Service Case Mgrs, HR Mgr, Intake/Trng Coord – Eagan; Jim Bohmbach, Production Mgr; Case Mgrs, Zumbrota Site Mgr, Employment Services Mgr – Red Wing From: Carolyn Dobis & Sally Ogren, Directors, Programs & Services Date: January 4, 2014. Re: Annual Incident Review & Report (January– December, 2013) Red Wing Analysis: As in other locations, a few individuals with difficult behaviors account for a disproportionate number of incidents. When there are issues with specific individuals, there is a plan for dealing with the behaviors in a controlled manner, and staff members are aware that the issues are probably situational or time-limited. It should be noted that again this year, we are counting an incident only once. Frequently an incident can involve a staff member, and two individuals or multiple occurrences of behavior, thus generating several documents for what is actually one incident. We have issued a discharge notice for one individual with moderately severe behavior issues. The other large group of incident reports represent accidents or falls. There was a serious injury related to a fall, a broken hip. It is not known which occurred first, the break or the fall. In a few cases, an existing injury may have been aggravated by or precipitated a fall. Staff members try to prevent falls as well as incidents with individuals who get upset easily, but are not always successful. Six individuals riding a Hiawathaland bus were not injured when the bus was hit in the rear bumper by a car, but incident reports were filed. There were also two errors reported to the Goodhue County VA reporting system.

Two individuals were dropped off at their home by a contracted driver where there were no staff members for a period of 10-15 minutes. The bus driver saw a car in the driveway & assumed staff members were present. Due to a long driveway, the driver could not easily see the individuals enter the house.

One individual was left at his home by a different bus company’s contracted driver where there were no staff members for a period of 10-15 minutes. The bus was earlier than usual. The result of the investigation of these two incidents was that these drivers were retrained and directed not to leave ProAct until 3:15 Monday through Thursday or 1:15 on Fridays. Other drivers also received retraining on transportation policies and individual risk management plans.

Causes, Trends, Actions for Improvement & Prevention of Recurrence: We continue to find that some individuals with behavior issues improve when they participate in activities and/or work at the satellite location in addition to, or in lieu of, the Red Wing location. It is a more relaxed atmosphere and there tends to be more individual attention. It is treated like an outing for some individuals and so it is approached with a positive attitude and enthusiasm. There is more space to separate activities and it is a quieter atmosphere, which evokes calm interactions and less agitation. For some individuals, attending the satellite, even one day per week, has had a positive effect overall. In general, regardless of location, increased personal space, plenty of advance notice for transitions to other activities, and a regular schedule that includes some preferred activities will assist volatile individuals to remain calm.

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Individuals prone to falling are assisted by staff members when they walk, as much as possible, and given more time to move about and to avoid groups of individuals who might inadvertently cause a fall. Red Wing & Zumbrota serve a significant number of individuals who are older and/or have physical disability issues. Zumbrota Analysis: One individual received a broken ankle as she stepped off the bus steps. Another individual was bit by a peer as the peer walked by her. Incidents are rare as staff are generally in close proximity to individuals and are prepared to deal with known behaviors or falls. Causes, Trends, Actions for Improvement & Prevention of Recurrence: Zumbrota DT&H has continued to maintain an excellent safety record. Good communication, a positive & supportive atmosphere & teamwork enhance services to a difficult population. Overall, as an organization, incidents appear to be minimal and follow-up is thorough. Safety committees review injuries reported to worker’s compensation, seizure reports, and any unsafe conditions.

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*Designates review by safety committee and may include medical treatment MONTH Red

Wing Red Wing Satellite

Zumbrota Noted incidents – for totals refer to monthly incident review reports, for specifics refer to individual R-107’s or A-30’s

January X EE-One person slipped on ice. DTH - One person slipped on ice, two persons spilled hot food on arm

0 0

February X Z - One person slipped on bus steps, broke ankle, one tripped on wc tiedown & fell. DTH – 2 slipped on ice & fell, one fell on floor, gash in head, one tripped on tubing & fell.

0 X*

March X EE – one, poor attendance, one seizure/fell, one, lost balance/split lip. DTH – One, ate first aid cream, one tripped, fell on knees.

0 0

April: X EE - One fall/hurt knee & wrist, one kicked peer, DTH – three touched inapp. by another, one pull hair, twist wrist, one ate sanding dust, one threw object, hit peer.

0 0

May X EE - One fell from chair,hit ground, DTH – one EUCP.

0 0

June: X Three falls, one, aggression to staff 2X, two left on bench unsupervised 5 min, six, motor vehicle crash, no injuries **One medication error, reviewed w med passer, sent to PH nurse.

0 0

July: X EE-one agitated behavior DTH- one choked, two eloped, two peer to peer aggressions, one left alone in community ,bus ran into/damaged walker

0 X Tripped & fell on stairs

August X EE – one fall, one aggression, DTH – one fall, two peer to peer aggression, two, bus driver did not check for home staff, reported, investigation.

0 0

September X* DTH - One left on bus, returned to ProAct. One, peer to staff,aggression. EE - two injuries,one dropped off home, no staff.

0 X One peer to peer aggression

October X DTH – one eloped, one peer to peer aggression, one tripped

0 0 **Two medication errors, reviewed w med passers/sent to PH nurse

November X DTH - One fell, two peer to peer aggression, one stealing money on job, one, no injury (bus accident), one inapp touch peer.

0 0

December X* DTH - Two individuals aggressive behavior to staff, EE, thumb injury while working

0 0

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MANDATED REPORTERS

All employees are mandated to report a suspected or observed maltreatment of a minor or a vulnerable adult as soon as possible (within 24 hours) or within 24 hours of the receipt of knowledge.

Such reports shall be promptly investigated by the Director, Programs & Services, Sally Ogren, who has primary responsibility, or by the President, Steven Ditschler, who has secondary responsibility and reported to the Common Entry Point Intake Worker, 385-3232, within 24 hours of knowledge. The secondary person must be involved to receive reports and forward them to the common entry point and to ensure that internal reviews are completed when there is reason to believe that the primary person was involved in the alleged or suspected maltreatment.

Or--every employee has the right to report all suspected maltreatment of a vulnerable minor or adult directly to the Common Entry Point.

Specific instructions for reporting should be followed as in our Vulnerable Minor or Adult/Maltreatment Policy and Procedure Manual. (I-78-Policy/Procedures)

Form R-107 should be used to immediately describe the incident in detail. Form A-30 should be used in lieu of R-107 if there was an injury requiring treatment or that may require treatment. The R-132 Vulnerable Adult/Maltreatment Report Form will be used by ProAct, Inc. to notify the status of a suspected maltreatment report, and will be provided to the reporter within two working days in a manner that protects confidentiality.

Revised 03/06/2012 Maltreatment of Minors/Vulnerable Program Abuse Prevention Plan I-78

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PROACT, INC.

STATUS OF REPORT OF SUSPECTED MALTREATMENT

CONFIDENTIAL TO: _____________________________ (mandated reporter) FROM: _____________________________ _____________________________ _____________________________ On ________________, at ____________ a report of suspected maltreatment was received from (date) (time) you. This report was (was not) forwarded to ___________________________ on __________ (common entry point) (date) for further evaluation and investigation of the suspected maltreatment. If you are not satisfied with the action taken by this agency, you may choose to contact the ______________________________ directly. (common entry point) AS REQUIRED BY MINNESOTA STATUTES, SECTION 626.557, YOU ARE HEREBY NOTIFIED THAT THIS FACILITY MAY NOT PROHIBIT A MANDATED REPORTER FROM CHOOSING TO REPORT AN INCIDENT TO AN EXTERNAL AGENCY. THIS FACILITY MAY NOT TAKE RETALIATORY ACTION AGAINST ANY MANDATED REPORTER WHO REPORTS AN INCIDENT TO THE COMMON ENTRY POINT IN GOOD FAITH. (Minnesota Statutes, sections 626.557, subdivision 4a, paragraphs (c) and (d)). NOTE: THIS FORM MUST BE PROCESSED WITHIN 24 HOURS. New 1/98 Revised 6/99, 7/01, 03/02, 03/03, 01/04 Board Approved: 04/02, 05/04

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POPULATION ASSESSMENT: 1. Age range of persons receiving services:

Our current population is persons 18 to 77. Exceptions to the upper age range could be made depending on an analysis of the person and each situation.

2. How will the program reduce the potential of abuse and/or harm to people related to the age of people receiving services?

The persons served are treated as individuals and age is one factor to be taken into

consideration. Staff members are trained on relevant factors and the appropriate type and amount of help to offer as needed. A young person could need some help exercising judgment in certain situations, or understanding the appropriate interactions with elders, and an older person may need some extra time to get from one place to another, with meals, in the bathroom and with ambulation, in some cases. The IAPP can detail specific areas in which staff members need to be trained.

3. Gender of persons receiving services:

Our population is currently male (56%) and/or female (43%), other/unknown (1%).

4. How will the program reduce the potential of abuse and/or harm to people related to the gender of people receiving services?

Staff members are trained to understand that privacy and confidentiality are required to protect

persons served. This applies to gender and sexuality as well. Information on individuals who are changing gender or who have certain preferences is protected by the case managers and is not shared as per HIPPA rules. Advocacy services are available and external referrals will be made upon request or as needed. Staff members are trained to be objective and neutral with gender and other issues, and to respect the rights and dignity of all persons served. Individuals served who exhibit tendencies to disrespect others’ preferences will be counseled and offered information to broaden one’s perspective on such issues.

5. Describe the range of mental functioning of persons receiving services

Intellectual /cognitive disabilities: mild, moderate, severe, profound to well above average; pervasive developmental disability, Asperger’s syndrome, autism spectrum disorders, seizures. Mental illness: schizophrenia, dysthymia, bi-polar disorder, anxiety, depression. Traumatic brain injury.

6. How will the program reduce the potential of abuse and/or harm to people related to the

mental functioning of people receiving services? ProAct provides specialized services for people with mental illness – the ARMHS program. Staff

members have extensive training and work closely with participants. There are additional requirements and documentation for individuals receiving these services. Counseling, classes, groups and attention to individualized needs, under the clinical supervision of a staff member from the Hiawatha Valley Mental Health Center ensure that needs are met. A monthly “core

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team” meeting of mental health professionals reviews individual’s progress in this and other related programs.

7. Describe the range of physical and emotional health of people receiving services: ProAct serves a group of people with 72% multiple disabilities (physical and/or emotional).

Physical functioning and abilities range from normal physical condition to significant dependence on others for activities of daily living. Disabilities of persons served may range from visual impairments, mental illness, hearing deficits, epilepsy, non-ambulation, and sensory/motor problems which affect coordination, movement, communications, and ability to understand one's surroundings, and other conditions. Red Wing has 33 individuals in wheelchairs or whose disabilities limit their ability to maove away from an aggressor and who must be assisted by staff members. Their individual plans address specific ways to protect each one from harm.

8. How will the program reduce the potential of abuse and/or harm to people related to the physical and emotional health of people receiving services served? Through contracted services, assessments followed by therapy services are provided when ordered by a physician. Staff members are trained on information related to physical and emotional health and oriented as needed on specific information related to each person’s needs, initially and as needs change or annually thereafter. New information on related subjects is integrated into staff training on a regular basis. Specific staff training is provided for individuals with specialized needs such as a feeding tube, food management (Prader-Willi), individuals with obsessive/compulsive disorder, blindness, individuals in wheelchairs.

9. Describe the range of adaptive/maladaptive behavior(s) of people receiving services: Included in this population are individuals who are upset by changes in environment, routine,

coworkers, schedules, rituals, classroom and/or work routines or schedules, medication, home, or roommate changes or disruptions, self-abuse, aggressive behavior toward co-workers, staff, or both; and power struggle or control issues that result in inappropriate behavior affecting others. Behaviors observed may include wandering/running away, attention getting and occasional non-compliance with program activities. Red Wing has 28 persons who have been aggressive to others in the past.

10. How will the program reduce the potential of abuse and/or harm to people related to the adaptive/maladaptive behavior(s) of the people receiving services served? Staff members are trained to use intervention strategies for behavior management as needed, according to individual plans, before they begin to work with persons served, annually, and as needed. ProAct–Red Wing offers Crisis Prevention Institute (CPI) training to staff members. Individual program plans are designed with supports to help increase adaptive behavior and decrease maladaptive behavior, and provide consistency through staff training among all staff working with the person served.

11. Describe the need for specialized programs of care for people receiving services:

Each person who participates in programming has individual needs, desires, goals and objectives related to health, general happiness and well-being, vocational dreams or goals, physical issues/needs requiring trained staff to appropriately assist with personal cares, lifting/transferring, medication monitoring or management, mental health management, wound care, behavior management, leisure activities, interpersonal and community interaction, and

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vocational, volunteer or craft pursuits.

12. How will the program reduce the potential of abuse and/or harm to people related to the need for specialized programs of care for people receiving services? Staff orientation and training is provided initially, annually and as needs change for Individuals requiring specialized programs of care. In some situations, a nurse or family member may teach programs of care or monitor procedures so that the person served, particularly if non-verbal, receives the care as designed and so that it meets the needs of the person. Communication among the person served and team members could enhance the process so that specialized services are delivered in the most comfortable and efficient manner possible for the person.

13. Describe the need for specific staff training to meet individual service needs: Staff members need to be trained not only on the knowledge needed to understand a range of

disability conditions and behavior management techniques, but on the specific and individual needs of the persons they are working with, in order to properly assist with daily needs, activities, goals and objectives. Because most persons served have multiple disabilities, an understanding of the interaction between physical disabilities and mental health or cognitive issues is important for appropriate care and assistance for the whole person.

14. How will the program reduce the potential of abuse and/or harm to people related to the need

for specific staff training designed to meet individual service needs? Case managers supervise and communicate with direct service staff members when it comes to

implementing programs and services. HST’s and job coaches are trained on a need to know basis with specific training designed to meet individual service needs. The individual plan and related goals and objectives are included in the training provided to staff members so that they understand and are able to assist persons served in their daily schedules and activities, which may include exercise, medication, work, community activities, volunteering, and/or personal care, meals, transportation or other needs. Staff members are trained in Crisis Prevention Institute techniques for appropriately defusing behaviors that hold the potential for abuse.

15. Describe any knowledge of previous abuse that is relevant to minimizing the risk of abuse to

people receiving services: There are ten individuals who have been abused, may be abusive to others, may be self-abusive

or who have behavior issues. If a person with a history of sexual offenses is accepted for services, it is essential that staff members carefully follow the plan for services so as to minimize risk of harm to others. Each person served who has a history of being abused or abusing others needs to be carefully monitored and to have a clear plan of action for dealing with situations that may arise.

16. How will the program reduce the potential of abuse and/or harm to people related to the

knowledge of previous abuse? Research and experience have shown that individuals who have been abused frequently continue to display maladaptive behavior and may be fearful, anxious, disruptive and/or abusive to others. They may become aggressive in response to upsetting situations, the behavior of others, certain personalities, or staff who approach them in certain ways. The staff members receive orientation and training to general principles as well as specific individualized plans of care for persons served who have histories of abuse. Training is provided to staff members so

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that consistency among staff members and predictable responses based on a team-generated plan will generally help to provide a secure environment. Staff training will be provided so that any incidents that could occur are dealt with according to the individual plan and so that individuals who have been abused are adequately protected from further abuse.

PHYSICAL PLANT ASSESSMENT: 1. Describe the condition and design of the facility as it relates to safety for the people receiving

services:

RED WING INDUSTRIAL PARK LOCATION: The Red Wing facility is located in a section of ProAct - Red Wing plant in the Industrial Park, approximately five miles north of Red Wing. The building meets all fire and safety requirements. It is an integrated plant, employing production workers as well as adults with disabilities. Restrooms are fully accessible. All persons are oriented to moving to areas of safety or exit in case of emergency or fire. There are three electric doors providing egress from the break room that allow independence for those with ambulatory problems. Any person subject to wandering remains under staff supervision throughout the entire day. There is a Wanderguard unit on the exit door for an individual with a Wanderguard bracelet, worn for safety purposes. Persons are supervised as needed when in areas of the building shared with participants and staff of other programs, production workers, and visitors. Two additional automatic door openers have been installed in the men's and women's bathrooms adjacent to the lunchroom in the newer section of the building. The fire door between the old & new sections of the building and the exit door nearest the classrooms have electric door openers. The fire bell warning system includes red flashing lights for hard of hearing/deaf persons. The front office has a lowered, accessible front counter and an automatic opening door.

The facility has access to a number of community work sites to provide both work services and community orientation services. Each work site is assessed by ProAct, Inc. staff members prior to beginning the job. Each person is then oriented to the work site and supervision is provided according to established ratios combined with other factors. Work sites and assignments are subject to change based on individual needs and responses to that environment.

Persons needing a variety of life skills activities, daily personal care, or needing additional supervision due to vulnerabilities or health problems are served in appropriate areas of the building space. DTH services areas include a large conference room, a kitchen and dining area, five bathrooms (one with a ceiling lift) two work rooms, a life skills room, lounge, three offices, two sick/relaxation rooms, laundry facilities, lockers and computer nooks. The area is fully accessible with a production area of approximately 2000 sq. ft, with two classrooms and a quiet room adjacent to the area. Persons needing other types of programming would be served in other areas of the building, housing a breakroom, kitchen area, a shower room, bathrooms in four locations of the building, the workfloor, three conference rooms, a large classroom, case manager offices, a job coach room, a janitorial standards measurement room, and an exercise room that is shared among all programs.

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3195 Neil Armstrong Blvd.

Eagan, MN 55121

651-686-0405

204 Mississippi Ave.

Red Wing, MN 55066

651-388-7108

224 Main Street

Zumbrota, MN 55992

507-732-7888

1202 Beaudry Blvd

Hudson, WI 54016

715-410-4216

Established January 1, 2014

PROGRAM ABUSE PREVENTION PLAN

I-78

2. How will the program reduce the potential of abuse and/or harm to people related to the condition and

design of the facility in terms of safety for people receiving services? There is an active safety committee that reviews all aspects of building and environmental safety,

including accidents, transportation issues, weather conditions, barriers, emergency preparations and needs. Being CARF accredited, there is an extensive set of health & safety standards that must be met. Because the facility is divided into sections, and then into rooms, as well as a large workfloor, staff members are assigned so that all areas of the building are covered. Any areas of the building that are off limits are posted and or secured in such a way that they are not accessible.

3. Describe any areas of the facility that are difficult to supervise:

The loading dock is an area that is not always supervised.

4. How will the program reduce the potential of abuse and/or harm to people related to the areas of the facility that are difficult to supervise? Individuals served who are authorized to enter the loading dock area are trained on safety, and on their specific duties in that area. Staff members who work in the vicinity of the loading dock and see someone who may not be safe, or who doesn’t belong there would ensure that the person would be safe and would call for an appropriate staff person or would escort the individual to his or her program area.

ENVIRONMENTAL ASSESSMENT:

1. Describe the location of the facility including information about the neighborhood and community that the facility is located: The facility is located in an industrial setting. Truck traffic is routed to the back of the building. Adjacent companies are generally acquainted with ProAct-Red Wing clientele. ProAct-Red Wing has landscaped and fenced an outdoor lawn area behind the day services section of the building. This provides a secure outdoor access for breaks and recreational activities. The area contains flowers, raised beds for flowers and vegetables and accessible picnic tables as well as poly tables & chairs. There is a shelter to protect consumers from the sun that is fully accessible. There is a garden behind this area where vegetables and herbs are grown. Whenever individuals are working in the garden, there is a staff member working with them and supervising the activity, ensuring that individuals are safe and appropriately engaged. Persons receiving services who are inclined to wander off grounds are monitored by staff, and appropriate action is taken to ensure their safety. ProAct-Red Wing has an elopement policy which is implemented as needed. Staff members supervise all breaks and pre-work time. Surrounding businesses typically will call ProAct-Red Wing if they notice a vulnerable adult going up the street. Whenever areas of potential hazard to persons served or staff are reported, appropriate action will be taken within 24 hours to correct the problem. If more time is required, the hazard will be secured to prevent access by a vulnerable adult.

2. How will the program reduce the potential of abuse and/or harm to people related to the location of the facility, including factors about the neighborhood and community?

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3195 Neil Armstrong Blvd.

Eagan, MN 55121

651-686-0405

204 Mississippi Ave.

Red Wing, MN 55066

651-388-7108

224 Main Street

Zumbrota, MN 55992

507-732-7888

1202 Beaudry Blvd

Hudson, WI 54016

715-410-4216

Established January 1, 2014

PROGRAM ABUSE PREVENTION PLAN

I-78

ProAct has an elopement policy to keep individuals served safe. When a person elopes or goes off grounds, a search is immediately begun. Unless individual protocols state otherwise, the police are called after an allotted time period to aid in the search. Occasionally, an individual will walk up the street and staff members will go after them and walk them back to the facility, explaining that safety is our first concern and that is why we have rules about not going off grounds. Our neighbors are acquainted with us and are extremely safety conscious. Our closest neighbor provides work to us and also employs some of our individuals in their facility and thus have been educated about the needs and abilities of individuals with disabilities that we serve.

3. Describe the type of grounds and terrain that surround the facility: The facility is in the midst of an industrial park, surrounded by streets, other factories/businesses, grassy areas, trees, and parking lots. The city bus serves this area. However, in close proximity (i.e. a three mile radius) is a state-managed bike trail, more streets, highway 61, and marshy areas adjacent to the Mississippi River, as well as a small shopping center.

4. How will the program reduce the potential of abuse and/or harm to people related to the type of

grounds and terrain that surround the facility? Significant efforts take place to keep the ProAct parking lot and sidewalks clear of snow and ice or other

hazards in inclement weather. There is a Wanderguard on the DTH door to keep one individual safe. When a new person to be served begins services, the person is oriented to all aspects of the facility, including the rules about staying in the building, going outside for breaks in nice weather only when accompanied by a staff person, or if able to go outside independently for breaks, then the person is trained to respect the boundaries of the property, and also safety rules. If the history of an individual includes possible elopement, then a plan is developed to keep that person safe, and that may include designating areas to search immediately, such as the bike trail for one individual who has eloped previously. When a search is necessary, there is a plan that is followed which includes searching the grounds of business and/or field or woods nearer to the river and at the same time searching toward the highway to prevent unsafe behavior near two potentially hazardous areas.

5. Describe the type of internal programming provided at the program:

Person-centered programming of an appropriate type is provided at the facility depending on the individual plans, ratios, whether employment services or day services are requested, the type of work available, the individual schedules of participants, the skill levels, amount of work available, whether individuals prefer community work, whether medication monitoring or management is needed, transportation schedules, and other factors, including behavior issues. Flexible programming related to work, work training, classes, abilities, interests, and other factors such as type of funding/rules shape internal programming.

6. How will the program reduce the potential of abuse and/or harm to people through the type of internal programming provided at the program?

Individual plans and funding rules guide the programming for each person. The potential for abuse or harm is reduced by having a suitable level of supervision available, by IAPP information which is

Page 23 of 24

3195 Neil Armstrong Blvd.

Eagan, MN 55121

651-686-0405

204 Mississippi Ave.

Red Wing, MN 55066

651-388-7108

224 Main Street

Zumbrota, MN 55992

507-732-7888

1202 Beaudry Blvd

Hudson, WI 54016

715-410-4216

Established January 1, 2014

PROGRAM ABUSE PREVENTION PLAN

I-78

provided to staff members as training to keep individuals safe, by doing assessments which help staff program appropriately for a person’s needs, and by monitoring interactions and functioning to keep people safe.

7. Describe the program’s staffing pattern:

There are 71 full-time and four part-time staff members. The various programs provided in this facility and in the community are set up to appropriately staff services depending on the ratios prescribed in the individual plans; and areas of the building are also organized in such a fashion that individuals served are grouped so that they will be served by appropriately trained staff persons who are available in appropriate numbers to provide services. Individuals on the extended employment workfloor needing minimal supervision to accomplish their assigned tasks are in a different program with a different ratio of supervisors to persons served. While each person served has a case manager, individuals served in the DTH program may be closely supervised and receive a more intensive level of services, on the higher end of the spectrum of needs.

8. How will the program reduce the potential of abuse and/or harm to people through the program’s staffing pattern?

A greater number of trained staff members are assigned to serve individuals with the highest level of need. Within that framework, there are certain individuals sensitive to noise, activity, certain other individuals, and they will have a different staffing pattern both for protection and for positive support. On the workfloor, in community activities, persons served are given choices, because that helps to prevent stressful situations of unhappy people. Staff members are also crosstrained to be able to assist and/or fill in as needed to provide flexibility to the programs. Regular, ongoing training on disabilities prepares staff members to remain competent and to develop expertise on individual needs

EACH PROGRAM MUST ENSURE THAT: A. People receiving services are provided with an orientation to the program abuse prevention plan. This

orientation must be within 24 hours of admission or within 72 hours for individuals who would benefit from a later orientation.

B. The ProAct’s governing body must review the program abuse prevention plan at least annually. C. A copy of the program abuse prevention plan is posted in prominent places in the facility and is

available, upon request, to mandated reporters, people receiving services, and legal representatives. D. The plan includes a statement of measures that are taken to minimize the risk of abuse to the vulnerable

adult(s) or when the need for additional measures is identified. This includes identifying referrals that are made when the vulnerable adult is susceptible to abuse outside the scope or control of ProAct Inc.

E. If the assessment indicates that the vulnerable adult does not need specific risk reduction measures in

addition to those identified in the program abuse prevention plan, the individual abuse prevention plan does document this determination.

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3195 Neil Armstrong Blvd.

Eagan, MN 55121

651-686-0405

204 Mississippi Ave.

Red Wing, MN 55066

651-388-7108

224 Main Street

Zumbrota, MN 55992

507-732-7888

1202 Beaudry Blvd

Hudson, WI 54016

715-410-4216

Established January 1, 2014

PROGRAM ABUSE PREVENTION PLAN

I-78

F. In addition to the program abuse prevention plan, an individual abuse prevention plan is developed for

each new person receiving services. A review of the individual abuse prevention plan is done as part of the review of the program plan. The persons receiving services participate in the development of the individual abuse prevention plan to the best of their abilities. All abuse (individual or program) prevention plans are reviewed at least annually by the interdisciplinary team.

____________________________ ___________________________ __________ Print name and title Signature Date Date(s) of last plan review: _______________ __________________ _________________ ---------------------------------------------------- ---------------------------------------------------------- Print name of County Licensor Signature of County Licensor Date Who reviewed this plan Legal Authority: Minn. Stat. § 245A.65, subd. 2